A&WMA Georgia Regulatory Update Conference Current State of
the Air in GA Jac Capp, GA EPD, Branch Chief, Air Protection Branch
April 16, 2013
Slide 2
Existing Nonattainment Areas (except ozone for 2008 NAAQS) All
these areas are now meeting the air quality standards. 1997 ozone
NAAQS (84 ppb 8-hr ave.) 1997 PM 2.5 annual NAAQS (15 ug/m3 annual
average) EPD is working to get all these areas redesignated back to
attainment. Ozone SIP submitted to EPA 4/4/12 Proposed Approval in
FR 2/4/13 PM 2.5 SIPs: Floyd: Submitted to EPA 6/21/12 Macon:
Submitted to EPA 6/21/12 Chattanooga: Submitted to EPA 9/14/12
Atlanta: Submitted to EPA 8/31/12 EPA must publish approval of all
plans in the Federal Register
Slide 3
Pollutant NAAQS Prom. Date Governors Rec. Due to EPA
Designations Effective 110(a) SIPs Due (3 yrs after NAAQS
promulgation) Attainment Dem. Due Attainment Date Notes &
Impacts to GA OzoneMarch 2008March 2009July 2012March 2011 N/A
(Marginal) Dec. 2015 (Marginal) 1. Only Atlanta is above this
standard (75 ppb). 15 counties designated nonattainment. 2. If
Atlanta does not meet attainment deadline, then bump up to Moderate
w/ Dec. 2018 deadline. NO 2 (primary) Jan 2010Jan 2011Feb 2012Jan
2013N/A 1. 1 roadside NO 2 monitor required in Atlanta by Jan.
2014. 1 more in Atlanta by Jan. 2015 and 1 in Augusta by Jan 2017.
2. All areas in GA meeting this standard 3. Permitting new NO 2
(combustion sources) more difficult. SO 2 (primary) June 2010June
2011 2013? Deferral? June 2013 Desig. + 18 months Desig. + 5 years
1. All areas in GA meeting this standard (Rome and Savannah are
close) 2. Permitting new SO 2 sources more difficult 3.
Implementation for deferred areas very uncertain CO August 2011 N/A
1. Standard unchanged 2.One roadside monitor in Atlanta by 2015
3.All areas in GA meeting this standard NO 2 /SO 2 Secondary March
2012N/A EPA retained the current secondary standards. PM 2.5/10
December 14, 2012 December 14, 2013 2015? (based on 2012- 2014
data?) December 2015 Desig. + 18 months Desig. + 6 years 1.Annual
PM 2.5 lowered to 12 ug/m3 2.One roadside PM 2.5 monitor in Atl. by
2015 3.Some areas currently above standard 4.Subpart 4 vs. 1 Court
decision raises questions Ozone 2014?2015? 2016? (based on 2013- 15
data)? 2017?2019?? 2022?? (Moderate) 1. More nonattainment areas
possible 2. Areas classified as moderate or above by EPA required
to implement I/M programs. 3. Boundary determinations are sensitive
Anticipated NAAQS Implementation Milestones
Slide 4
Ozone Design Values 2010-2012
Slide 5
8-hr Ozone, Annual 4 th Highest Value (ppm) for Each MSA 0.075
ppm standard
Slide 6
EPA Lowered Annual PM 2.5 NAAQS on December 14, 2012
Slide 7
Annual PM 2.5 Design Values 2010-2012
Slide 8
PM 2.5 Annual Averages (g/m 3 ) 201120122011 and 2012
Slide 9
PM 2.5 Annual Averages (g/m 3 ) Highest for Each MSA 12.0 g/m 3
standard
Slide 10
24-hour PM 2.5 Design Values 2010-2012
Slide 11
PM 2.5 24-Hour, 98 th % (g/m 3 ) Highest for Each MSA 35 g/m 3
standard *2012 partial year 35 g/m 3 standard
Slide 12
SO 2, Three Year Average 99 th % Daily Max 1-Hour Averages
(ppb)
Slide 13
NO 2, Three Year Average 98 th % Daily Max 1-Hour Averages
(ppb)
Slide 14
EPDs First Near-Road Monitoring Site: NO 2 January 1, 2014
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Slide 18
Startup, Shutdown, Malfunction (SSM) Proposed SIP Call June 30,
2011 - Sierra Club submitted petition to EPA February 22, 2013 -
EPA publishes in FR proposed findings of substantial inadequacy SIP
calls May 13, 2013 Comment Deadline After SIP Call is finalized,
expect ~18 months for States to submit SIP, ~18 months for EPA to
review and approve/disapprove SIP If EPA finalizes it by September
2013, a SIP revision would likely not be submitted prior to Spring
2015 and EPA would likely not make a decision on our SIP revision
before Fall 2016. All of this is sequential, so a delay at any step
results in an equivalent delay of EPAs final action on a possible
SIP revision. EPA may finalize a FIP at any time after EPA has
disapproved a SIP or has found that the state has failed to make a
required submission.
Slide 19
Startup, Shutdown, Malfunction (SSM) Proposed SIP Call
Preliminary concerns with EPAs proposal EPA did not consult with
States or hold any public stakeholder meetings prior to its
proposal Interferes with States right to develop its own SIP EPA
did not review all relevant sections of Georgias SIP Georgias SIP
complies with the Clean Air Act EPA is applying a different
standard to States SIPs than it is with its own standards under the
NSPS or NESHAP programs EPA doesnt know what the practical
implications are of their action (because they made no attempt to
do so)
Slide 20
The permit fee program has been required under the Clean Air
Act since it was amended in 1990. Congress assumed that a permit
fee of $25/ton, adjusted to the CPI, would be necessary to fund the
required permit fee program. Permit Fees In FY2013, Air Program
funding is projected to total $18.8 million (does not include
Radiation Program or pass through funds), with $12.4 million from
permit fees (66%), $3.7 million from federal grants (20%) and $2.7
million from vehicle emission testing program fees (14%).
Slide 21
If no changes were made to permit fees, in FY2014 we project a
deficit of nearly half million dollars. Not due to staffing
increases. Permit fee staffing levels have actually been
decreasing. Deficit primarily due to significant increases in
employers share of health and retirement expenses. Proposal:
Increase the industry and coal power plant $/ton fees by $1.50/ton
Increase the Title V minimum fee by $400 Permit Fees
Slide 22
Other Important Issues We Are Following Interstate Transport of
Air Pollution CAA Section 110(a)(2)(D)(i) Sulfur Dioxide
designations by EPA (or lack thereof) PM2.5 Court Decision
Regarding Subpart 1 vs. Subpart 4 implementation Precursors
Expedited Permitting
